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Consultation begins on eliminating tax benefits of trusts and certain estates
- Borden Ladner Gervais LLP
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- Canada
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- June 6 2013
In the March 2013 Federal Budget, the government announced its intention to consult on possible measures to eliminate the tax benefits arising from
Central management and control test determines trust residence for Canadian tax purposes
- Borden Ladner Gervais LLP
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- Canada
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- April 16 2012
On April 12, 2012, the Supreme Court of Canada (“SCC”) dismissed the taxpayer’s appeal in St. Michael Trust Corp. v. The Queen
Canada’s new tax avoidance transaction reporting regime
- Borden Ladner Gervais LLP
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- Canada
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- January 25 2011
Following similar initiatives by Quebec, the U.S, the U.K. and Australia, Canada has proposed a regime of mandatory disclosure for certain tax avoidance transactions entered into after 2010, as well as transactions that are part of a series of transactions that began before 2011 but is completed after 2010
Barbados spousal trust strategy fails Canadian trust and GAAR tests
- Borden Ladner Gervais LLP
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- Canada
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- October 7 2009
In Paul Antle and Renee Marquis-Antle Spousal Trust v. The Queen, the Tax Court considered a series of transactions implemented by a Canadian resident taxpayer known as a “capital property step-up strategy”
Central management and control determines trust residence
- Borden Ladner Gervais LLP
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- Canada
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- September 23 2009
In Garron, M. et al. v. The Queen, the Tax Court of Canada considered whether two Barbados trusts (the “Trusts”) were entitled to claim the benefit of the capital gains exemption in Article XIV(4) of the Canada-Barbados Income Tax Convention (the “Treaty”) on their dispositions to an arm’s length purchaser of shares of two Canadian holding corporations which indirectly owned a Canadian automotive parts manufacturing and assembly business
Current Search
- Jurisdiction - Canada
- Workarea - Corporate Tax
- Workarea - Private Client & Offshore Services
- Author - Stephanie Wong